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FH-1100 component retire items


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there is an FH-1100 for sale on ebay (http://cgi.ebay.com/ebaymotors/1969-Fairchild-Hiller-FH-1100_W0QQitemZ300032809880QQihZ020QQcategoryZ63680QQssPageNameZWDVWQQrdZ1QQcmdZV

iewItem), and the seller claims "no life limited components", however the TCDS list a retirement schedule. here is the letter he sent me to back up his claim:

 

Hello Mr. Braun

 

Shouldn't be any surprises. There are no life limited parts on the FH-1100, hence no life limited current status records. Overhaul times have never, ever been mandatory under part 91 for any aircraft. That is why we write operations specifications that make them mandatory when operating under part 135 or 121

 

Type Certificate Data Sheet information is not regulatory unless there is a regulation that makes that information mandatory.

 

There is no production certificate for the FH-1100 helicopter, hence the "factory" cannot perform maintenance or direct maintenance.

 

Status Update: The draft letter is complete and formatted; a copy has been provided to FAA HDQ General Counsel, and; I plan to hand carry it around next week for the various office concurrences; there are five.

 

The meeting and attendees are scheduled for Friday, September 15 at 1PM. Unless something pops up, we are good to complete this then.

 

Supposed to be a nice weekend. Optimum weather for enjoying a glass of good lager.

 

I will have something more for you next Wednesday.

 

 

Russell S. Unangst, Jr.

Special Assistant - Airworthiness, AFS-305

Aircraft Maintenance Division, AFS-300

Federal Aviation Administration Headquarters

Washington, DC

202-267-3786

 

 

 

-----AutoAirCon@aol.com wrote: -----

 

 

To: Russell Unangst/AWA/FAA@FAA

From: AutoAirCon@aol.com

Date: 09/07/2006 04:52PM

Subject: CSI that is killing me

 

 

Hello Russell:

 

Thanks for the update. I am sure you cannot tell what the letter is to say until it is signed. I would just like to know if there will be any surprises, or will it reflect what we have been discussing over the last million years, or so.

 

Thanks,

 

Rick B.

********************************************************************************

*****************************************

 

 

Here is the FAR that contradicts the above letter:

 

Sec. 43.10

 

[Disposition of life-limited aircraft parts.]

 

[(a) Definitions used in this section. For the purposes of this section the following definitions apply.

Life-limited part means any part for which a mandatory replacement limit is specified in the type design, the Instructions for Continued Airworthiness, or the maintenance manual.

Life status means the accumulated cycles, hours, or any other mandatory replacement limit of a life-limited part.

(B) Temporary removal of parts from type-certificated products. When a life-limited part is temporarily removed and reinstalled for the purpose of performing maintenance, no disposition under paragraph © of this section is required if--

(1) The life status of the part has not changed;

(2) The removal and reinstallation is performed on the same serial numbered product; and

(3) That product does not accumulate time in service while the part is removed.

© Disposition of parts removed from type-certificated products. Except as provided in paragraph (B) of this section, after April 15, 2002 each person who removes a life-limited part from a type-certificated product must ensure that the part is controlled using one of the methods in this paragraph. The method must deter the installation of the part after it has reached its life limit.

 

Acceptable methods include:

(1) Record keeping system. The part may be controlled using a record keeping system that substantiates the part number, serial number, and current life status of the part. Each time the part is removed from a type certificated product, the record must be updated with the current life status. This system may include electronic, paper, or other means of record keeping.

(2) Tag or record attached to part. A tag or other record may be attached to the part. The tag or record must include the part number, serial number, and current life status of the part. Each time the part is removed from a type certificated product, either a new tag or record must be created, or the existing tag or record must be updated with the current life status.

(3) Non-permanent marking. The part may be legibly marked using a non-permanent method showing its current life status. The life status must be updated each time the part is removed from a type certificated product, or if the mark is removed, another method in this section may be used. The mark must be accomplished in accordance with the instructions under Sec. 45.16 of this chapter in order to maintain the integrity of the part.

(4) Permanent marking. The part may be legibly marked using a permanent method showing its current life status. The life status must be updated each time the part is removed from a type certificated product. Unless the part is permanently removed from use on type certificated products, this permanent mark must be accomplished in accordance with the instructions under Sec. 45.16 of this chapter in order to maintain the integrity of the part.

(5) Segregation. The part may be segregated using methods that deter its installation on a type-certificated product. These methods must include, at least--

(i) Maintaining a record of the part number, serial number, and current life status, and

(ii) Ensuring the part is physically stored separately from parts that are currently eligible for installation.

(6) Mutilation. The part may be mutilated to deter its installation in a type certificated produce. The mutilation must render the part beyond repair and incapable of being reworked to appear to be airworthy.

(7) Other methods. Any other method approved or accepted by the FAA.

(d) Transfer of life-limited parts. Each person who removes a life-limited part from a type certificated product and later sells or otherwise transfers that part must transfer with the part the mark, tag, or other record used to comply with this section, unless the part is mutilated before it is sold or transferred.]

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and the seller claims "no life limited components", however the TCDS list a retirement schedule. here is the letter he sent me to back up his claim:

 

 

Russell S. Unangst, Jr.

Special Assistant - Airworthiness, AFS-305

Aircraft Maintenance Division, AFS-300

Federal Aviation Administration Headquarters

Washington, DC

202-267-3786

.]

 

I saw that one a while back, but was under the impression that "no life limited components" meant that none were included w/ the sale.

 

As far as i know the 1100 was type certificated ship & was produced IAW a production certificate. The new factory in Florida i know has issued SB's stating that field overhaul of the transmissions & some other parts is no longer acceptable & must be reutrned to them for overhaul/inspection. Not sure if they have a production certificate to manufacture new 1100's yet, but the existing ones are certificated aircraft & must be treated as such.

 

This FAA guy has a phone number, i suggest anyone interested in this 1100 call him AND the factory in Florida to get the full scoop.

 

I have talked to some of these "ebay-ers" about some of the wild ideas they have about certificated aircraft, & i would like to get ahold of whatever they are on for the weekends :lol:

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Here is the operating rule that requires the life limited parts in the helicoter to be replaced, as listed on the aircraft and engine type certificate data sheet.

 

91.409

 

(e) Large airplanes (to which part 125 is not applicable), turbojet multiengine airplanes, turbopropeller-powered multiengine airplanes, and turbine-powered rotorcraft. No person may operate a large airplane, turbojet multiengine airplane, turbopropeller-powered multiengine airplane, or turbine-powered rotorcraft unless the replacement times for life-limited parts specified in the aircraft specifications, type data sheets, or other documents approved by the Administrator are complied with.

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